Proposed Section 751(b) Regulations: An ‘Exchange’ for the Better?
123 J. TAX'N 52 (2015)
35 Pages Posted: 1 Jul 2017
Date Written: May 29, 2015
In 2014, Treasury and the IRS issued proposed regulations concerning so-called disproportionate distributions under section 751(b). The proposed regulations adopt many of the principles first announced in Notice 2006-14 — responses to which were “predominantly favorable” according to the Preamble of the proposed regulations. This article provides a technical overview of the proposed regulations and concludes by considering whether an exchange of the current regulations for the proposed regulations achieves Treasury and the Service’s goal of writing regulations that advance the purpose of the statute while enhancing simplicity for taxpayers.
Keywords: Section 751(b), Partnership Distributions, Proposed Regulations
Suggested Citation: Suggested Citation